Emergency Preparedness in Response to Terrorism

Emergency preparedness (EP) is a prudent defense-in-depth measure regardless how small the probability of a serious reactor accident or a terrorist attack. It is one of many defense-in-depth measures that can mitigate the public health consequences of a reactor accident even though nuclear safety regulations, engineering, and operations reduce the likelihood of such accidents. The existence of terrorist threats may affect the likelihood of a reactor accident, although it is not currently possible to estimate the change in probabilities with great confidence. However, EP requirements are not based on the probability of a terrorist-based attack on a nuclear plant in the same manner that they are not based on the probability of a reactor accident.

Impact of September 11, 2001, on Emergency Preparedness

The world has changed since the terroristic events of September 11, 2001, and in response, NRC took immediate action by advising nuclear power plants to go the highest level of security -- which they all promptly implemented. Shortly afterward, NRC and the industry reevaluated the physical security at the nation's nuclear power plants. In February 2002, the NRC issued Interim Compensatory Measures (ICMs) requiring all U.S. nuclear power plants to perform specific plant design studies, add additional security personnel, enhance physical protection features, improve EP, and provide additional training. Nuclear industry groups and Federal, State, and local government agencies assisted in the prompt implementation of these measures and participated in drills and exercises to test new planning elements.

In recent years, the NRC also formally reviewed the emergency preparedness planning basis to ensure that it will adequately protect the health and safety of the public in light of the current threat environment. The evaluation found that emergency preparedness at nuclear power plants remains strong, but could be improved in a few areas, such as communications, resource management, drill programs, and NRC guidance. The NRC is drafting new requirements that will include these improvements.

Protecting public health and safety has always been paramount in nuclear power plant design and operation. Robust structures, such as reactor containment buildings, protect the reactor. Safety systems, such as diesel generators, are redundant and independent. These design features provide excellent protection from external hazards, such as tornadoes and hurricanes, as well as nuclear accidents. The same design features also protect against potential acts of terrorism, making nuclear power plants among the most robust and well-protected civilian facilities in the country.

Physical security at nuclear power plants is provided by well-armed and well-trained security personnel who remain ready to respond to an attack 24 hours a day, seven days a week. The sites are protected by sensitive intrusion detection equipment, fences, and barriers all of which are monitored by cameras and security patrols. The NRC is conducting force-on-force (FOF) exercises using trained adversaries to ensure nuclear power plant security personnel can implement many new security improvements. NRC security specialists observe these exercises to ensure the licensee can implement emergency plans during a terrorist event. Additionally, NRC conducts routine inspections to ensure licensees comply with EP, security, and all other regulations.

The events on September 11, 2001, highlighted the need to re-examine the way the NRC is organized. As a result, the NRC created the Office of Nuclear Security and Incident Response (NSIR) in April 2002 to more effectively bring together staff expertise to focus on these areas. In addition to pulling staff from other areas within the NRC, the new NSIR office hired experts in security with civilian and military experience. Within NSIR, the NRC established the Division of Preparedness and Response (DPR) to integrate emergency preparedness with emergency response. The establishment and placement of this organization reflects another step in the NRC's ongoing efforts to increase attention on activities that affect emergency preparedness. DPR is responsible for developing emergency preparedness policies, regulations, programs, and guidelines for both currently licensed nuclear reactors and potential new nuclear reactors, as well as for certain materials, licensee facilities such as fuel cycle facilities.

In response to the current heightened security environment, the nuclear industry, through the Nuclear Energy Institute (NEI), with NRC support, has taken the initiative to develop guidelines addressing the unique challenges of security events to existing Emergency Preparedness (EP) programs. The NEI guidelines have encouraged industry to conduct unevaluated Hostile Action-Based EP Drills at all sites before 2010.

Consideration of Potential Terrorist Activities with Respect to Emergency Preparedness

NRC continues to conduct studies to determine the vulnerability of nuclear power plants and the adequacy of licensee programs to protect public health and safety in the post-9/11 threat environment. Whether the initiating event is terrorist based or a nuclear accident, the EP planning basis provides reasonable assurance that the public health and safety will be protected. EP plans have always been based on a range of postulated events that would result in a radiological release, including the most severe.

The NRC has also conducted analyses of spent fuel pool (SFP) vulnerability. The calculations have shown that SFPs are robust structures that are difficult to damage. Even under conditions in which fuel is damaged, current analyses predict the time to begin and magnitude of a release is consistent with that considered by the EP planning basis. However, additional calculations continue to be performed to ensure that a reasonable spectrum of initial and boundary conditions is evaluated.

From the studies completed thus far, it is clear that current decommissioning plant EP programs are adequate given the age of spent fuel contained in their pools. Modestly aged fuel will be air cooled under a loss of spent fuel pool water accident. The age of spent fuel dictates the time it would take to heat up the fuel, potentially releasing radioactive nuclides. All spent fuel at the current fleet of decommissioning plants is older than five years and is therefore very slow to overheat even under these more challenging conditions. Regardless of the spent fuel age or configurations considered, the current analyses show that spent fuel heat-up time is longer than previously estimated by NRC in draft NUREG-1738, "Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants," dated February 2001. Based on the analysis performed to date, the staff has not identified any spent fuel pool accident issues that would invalidate the EP planning basis.